August 11, 2021

The Health Care Standards Development Committee is responsible for developing recommendations for accessibility standards for Ontario hospitals. In August 2021, the Committee was seeking public feedback on their initial recommendations report. The proposed health care standards address solutions to identify, remove and prevent accessibility barriers faced by people with disabilities throughout their patient journey within hospitals.

Based on March of Dimes Canada’s long history as a service provider and advocate in Ontario, we submitted the following response to help make hospitals more accessible for people with disabilities. 

MODC welcomes the opportunity to provide input on the initial recommendations for the development of health care accessibility standards in Ontario. We applaud the work of the Standards Development Committee in developing such robust and detailed recommendations to address the multifaceted barriers experienced by people with disabilities in hospitals and other health care settings. 

In developing this feedback, we drew on our experience as a major provider of community support services and community-based programs across the province – including working in specialized areas such as assistive devices and supporting stroke survivors. In addition, we would like to take this opportunity to support the recommendations in the AODA Alliance's brief dated August 3, 2021.

Areas of strength

Overall, MODC broadly supports the initial recommendations put forward by the Standards Development Committee. We appreciate that the recommendations seek to address systemic barriers throughout the patient journey – from the actual administration and leadership of hospitals, to communications with patients, to education and training for health care providers. 

In the spirit of “nothing about us without us,” MODC appreciates that consultation with people with disabilities is a key feature of Recommendation 1 and is a common thread throughout the other recommendations. Recognizing that inclusive design must be a baseline decision-making lens, we welcome the Committee’s emphasis in Recommendation 1 that accessibility should be consistently considered as part of early, proactive hospital decision-making.

As a major provider of community support services in Ontario, MODC particularly endorses Recommendation 9, which proposes that hospitals shall ensure that there are policies, procedures and practices to provide persons with disabilities with appropriate, authorized personal support services. MODC has extensive experience supporting clients with disabilities through admission to and discharge from hospital. We have seen firsthand how barriers are perpetuated and a lower standard of care is delivered when third party supports, such as community care providers, are not seamlessly integrated into the hospital stay. 

As such, we appreciate the recommendation that the support is to be directed by the patient, and that if the patient chooses to use their existing services, that the hospital or health care provider is required to utilize these services without impediments. Importantly, we would add that to provide continuity of care, it is integral to ensure that appropriate personal support services are available pre-, during, and post-hospitalization. 

Strengthening the recommendations

While MODC is quite pleased with the initial recommendations overall, there are some limitations within the report that should be addressed to ensure that the intent of removing barriers for people with disabilities is achieved, alongside provision of a high standard of care. Our recommendations for strengthening the regulations are outlined below.

Patient-centred care, in hospital and in the community

While MODC recognizes that the mandate of the Standards Development Committee is to focus on the hospital sector, we strongly encourage the Committee to include framing that consider hospitals as part of the broader health care system. As Ontario moves toward providing less fragmented and more coordinated, patient-centred care via the Ontario Health Teams model, it is crucial to consider how barriers are removed across the continuum of care. By taking a hospital-by-hospital approach to accessibility planning, there may be a lack of recognition of community-based care and an overemphasis on the medical model. 

Recommendation 1: Accessibility planning 

MODC appreciates the flexibility provided in allowing hospitals to develop a consultation mechanism which works within their community and considers their local context. However, we recommend enumerating that accessibility plans and consultation mechanisms must consider the diversity of disabilities. Communication, sensory and cognitive accessibility must be considered alongside physical accessibility. If hospitals only consult with individuals with specific types of disabilities, the needs of other individuals can be missed. 

For example, clients served by MODC often find themselves in health care settings that are labelled as “accessible,” but which only meet the needs of someone with limited mobility and not someone who uses a large assistive device like a wheelchair. Direct consultation with individuals with diverse disabilities and lived experiences is crucial to understand the true accessibility requirements within hospital settings.

Recommendation 2: Consultation on procurement or facilities

Consultation with individuals with disabilities in procurement processes is an important step to remove barriers in the equipment, services and technology purchased. MODC also recommends the addition of policies and practices to embed inclusion and accessibility into procurement processes, such as including accessibility metrics in Request for Proposal evaluation processes and requiring vendors to complete AODA training as part of their service agreements. 

Recommendation 3: Access to equipment

MODC agrees with the Committee’s note that access to equipment also requires staff support, education and training on making hospital equipment accessible and how to use accessible equipment and assistive devices. 

However, access to equipment that enables health care services on-site does not go far enough to ensure people with disabilities are able to transition out of hospital to receive home- or community-based care. Beyond the on-site equipment, it is important to consider how the hospital supports access to equipment and technology that enables individuals with disabilities to be discharged and access in-home care.

Recommendation 5: Coordination of accessibility accommodations

Recognizing the importance of delivering more coordinated and integrated care, we appreciate the recommendation to communicate an individual’s accommodation needs when transitioning within or between health care organizations, including the transition to community care organizations. It is important to note that inviting community care partners into discussions about a patient’s accommodation needs and care is important for ensuring the patient is supported to stay home after discharge from hospital and avoid re-admission.

For many people with disabilities who receive community care and who are temporarily hospitalized, their care is transitioned from a community care organization, to a hospital, and back to the same community care organization. As such, there is a valuable opportunity to identify the community care partners in the individual’s support plan upon admission to hospital and involve them in ongoing accommodation and care conversations. Too often, community care organizations are not involved until discharge is imminent, resulting in reduced continuity of care and unnecessary barriers for the patient. 

Recommendation 6: Electronic health records

MODC welcomes the Committee’s recommendation that electronic health records include mandatory fields that enable the identification and provision of accessibility accommodations and support requirements for all patients with disabilities. Recognizing that not all hospitals and health care settings have moved to electronic records, we recommend that similar standards are placed on sites operating with physical records.

Also, in addition to ensuring that information gathered enables continuity of care for individual patients with disabilities, we also recommend that the fields added to health records are considered from a research and data collection lens. Records should be designed in such a way that they facilitate collection of data on the prevalence and types of disabilities, thus enabling data-driven planning and decision-making at the system level. With better data, we can build better systems and interventions for people with disabilities. 

We also recommend that opportunities are explored to take a more patient-centric approach to health records by integrating them with the patient’s other disability service-related records from across Ontario government agencies. Not only does integrated data mitigate data security concerns, but it removes the additional barriers and burden for people with disabilities who must constantly re-apply and re-enter the same information to access care and supports. 

Recommendations 8 and 9: Communication accommodation and respect for capacity and access to third party supports

MODC strongly supports Recommendation 8, that persons with disabilities must be provided accommodations to improve two-way communication, including that health care providers must recognize, understand and respect the capacity of all people with disabilities to be full participants in their care. For example, it is very common for health care providers to assume that someone with a communication disability does not have the capacity to direct their own care, when they do have the capacity with access to a communication aid and/or support person. As the Committee recommends, health care staff training is an important component of removing this barrier.

However, it is important to note that “authorized support persons” should not become exclusionary based on the worker’s specific designation. In both Recommendation 8 and Recommendation 9, related to third party supports, MODC encourages the Committee to include an understanding that the qualifications of personal support services vary from region to region across the province, and thus regulations should not focus on a specific designation. In absence of a provincial Personal Support Worker registry, the regulations should accommodate those support workers already in the sector to enable continuity of care.

Recommendation 17: Accessible complaints process

MODC appreciates the recommendation that the current requirements for patient complaints processes are augmented to include additional accessibility measures. In addition to this formal complaint process for patients, it may be beneficial to introduce a complaint or feedback process for community care partners, who often have a detailed understanding of issues that unfold during care transitions and the discharge process. 

Addressing gaps: Virtual care as accessible health care

Notably, the only references to virtual care within the recommendations are with regards to provision of care during public emergencies such as the COVID-19 pandemic. While virtual care or telehealth is not accessible for all people with disabilities, it is important to consider virtual care appointments as a viable accessibility option for some patients’ hospital visits. 

At MODC, we have seen the benefits of virtual services and programs firsthand. During the COVID-19 pandemic, we pivoted to offer all our non-essential services virtually and saw enormous success in making these opportunities accessible for individuals who could not previously access them.

For individuals who face barriers to physically arriving at a hospital or health care setting (including lack of accessible transportation or access to support workers), a virtual appointment may be the more accessible option. For example, perhaps a virtual consultation can be offered to determine if a patient needs to have an in-person follow-up. While virtual care should not be the only option available, it should be offered as an important option to facilitate removal of barriers for some patients.